Legal Requirements for Use of Perkins IV Funds
Index
General Authority
Allocations
Consortium Guidance from Perkins IV
Allocation of Funds within a Consortium
Reallocation of Perkins Funds
Supplanting
Crosswalk of Federally Required Activities for Use of Perkins Funds:
Required Elements and Associated Policy of the CTE Programs of Study
Local Improvement Plans
All Aspects of Industry
Technology
Evaluations
Improving and Expanding CTE
Sufficient Size, Scope and Quality
Special Population
Permissive Use of Funds
Funds to a Consortium
Supplanting
Developing, implementing and improving CTE POS
Education and Business Partnerships and Collaboration
School to Career Activities
Career and Technical Student Organizations
Equipment:
Equipment must be “allowable” and improve student performance.
Equipment Maintenance
Equipment Labeling and Inventory
Equipment Shared with Disciplines other than CTE
Supplies
Facility Construction
Professional Development
Teacher Education Costs
Interdisciplinary /Integrated Curriculum Program Expense
CTE Teacher Training
Teacher Travel to National/State Conferences
CTE Professional Organization Memberships
CTE Teacher and Staff Salaries
Transitions to Postsecondary
New CTE Courses
Learning Communities
Middle School Students
Career Guidance
Mentoring and Student Support
Adults and drop-outs
Training in non-trad fields
Entrepreneurship
Automotive technologies
Family and Consumer Science
Capital Expense
Non-Allowable use of funds
Oregon Department of Education 2009
Legal Requirements for Use of Perkins IV Funds 2007-2013
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Legal Requirements for Use of Perkins IV Funds
General Authority
The primary use of Perkins funds received by the eligible recipient is to improve or expand career
education and improve student academic and technical performance. Perkins IV cannot be used
to maintain career education program.
Allocations
The formula for determining the allocation of Perkins IV funds is established in Federal legislation
and supports stand-alone (LEA that meets $15,000/$50,000 threshold) or a consortium of LEAs
that work together to achieve the priorities of the legislation.
Consortium Guidance from Perkins IV
Sec 131 (Secondary) provides the flowing guidance on consortia
Consortium Requirements -1. ALLIANCE- Any local education agency receiving an allocation that is not sufficient to
conduct a program which meets the requirements of section 135 is encouraged to –
A. form a consortium or enter into a cooperative agreement with an area career and
technical education school or educational service agency offering programs that meet
the requirements of section 135;
B. transfer such allocation to the area career and technical education school or
educational service agency; and
C. operate programs that are of sufficient size, scope, and quality to be effective.
2. FUNDS TO CONSORTIUM.—Funds allocated to a consortium formed to meet the
requirements of the subsection shall be used only for purposes and programs that are
mutually beneficially to all members of the consortium and can be used only for programs
authorized under this title. Such funds may not be reallocated to individual members of
the consortium for purposes or programs benefiting only 1 member of the consortium.
A. Data.—The Secretary shall collect information from eligible agencies regarding the
specific dollar allocations made available by the eligible agency for career and
technical education programs under subsections (a), (b), (c), (d), and (e) and how
these allocations are distributed to local educational agencies, area career and
technical education schools, and educational service agencies, within the State in
accordance with this section.
Allocation of Funds Within a Consortium
The allocation of the Perkins Grant must be done at the consortium level. The consortium
CANNOT “grant back” the money to the individual schools. The legislation is very clear that a
grant back situation can cause the entire amount to be reclaimed by the US Department of
Education.
Example: If a school generates $5,600 through the formula and cooperates with a consortium, they are
not guaranteed $5,600 to be spent on their career education programs. The consortium must review
the career education needs of all the schools and allocate the money on business education, then all
business education programs in the consortium must have the opportunity to participate.
The consortium members must have input on the allocation of funds. Any equipment or
instructional materials purchased remain the property of the consortium and must be clearly
identified as such.
Reallocation of Perkins Funds
Federal funds that are not applied for as of September 1 of the current fiscal year will be
reallocated by formula for use during the following fiscal year to LEA’s with application approved
for federal funding.
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SUPPLANTING vs. Supplementing
Grant recipients must monitor expenditures to ensure that Perkins federal funds are not
supplanting the general requirements of local education agencies. The law is designed to ensure
that federal funds pay for something extra, not day to day operational costs.
Grantees may no use federal funds to pay for services, staff, programs or materials that would
otherwise be paid for with state or local funds.
Local Education Agencies must provide all the state and local fund needed to operate in the
absence of federal funds. (i.e. routine operating expenses such as building maintenance and
repairs, landscaping and custodial service, basic teacher and student equipment and supplies).
Presume supplanting:
Use Perkins funds to provide services the recipient is required to make available under
other federal, state or local laws
Use Perkins funds to provide services the recipient provided with state or local funds
in the prior year
Questions to ask- Making Decisions About Equipment
Equipment:
1. Will the purchases be used exclusively to help improve technical and/or academic
performance of students enrolled in courses associated with CTE Programs of Study?
2. Was the expenditure appropriately identified in the annual plan and budget?
3. Will the costs of capital expenditures (infrastructure enhancement) such as wiring, plumbing
or construction to a facility?
4. Will the funds be used to purchase equipment with a unit cost of $5,000 or more?
5. Are the purchase being made in time to meet the “allocable” requirements?
6. Will the funds be used to upgrade, replace or repair existing equipment previously purchased
by Perkins?
Making Decisions About Supplies:
1. Will the funds be uses to purchase consumable products with a life of less than 1 year?
2. In the past, have the supplies been purchased using general funds or other grant funds?
3. Will the supplies be used in a manner that supports the increase in student performance in a
CTE POS this year?
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Federally Required Activities For Use of Perkins Funds
Required Elements and Associated Policy for CTE Programs of Study
Note: Eligible recipients must first satisfy the Perkins IV required activities before any expenditure of
funds are permitted for permissive activities [Sec. 135(c)]. However, required activities may also be
accomplished through existing general fund supported programs and policies and/or other federal,
state, or local funding sources.
“(a) General Authority. - Each eligible recipient that received funds under this part shall use such
funds to improve career and technical education programs.
“(b) Requirements for Uses of Funds.- Funds made available to eligible recipient under this part shall
be used to support career and technical education programs that Oregon has adopted the CTE Program of Study (CTE POS) as the focus for all Perkins IV funded
career and technical education. Required activities are integral to the development of
Oregon’s four Core Elements of the CTE POS: 1) Standards and Content, 2) Alignment and
Articulation, 3) Technical Skills Assessment and 4) Student Support Services. While not all
existing CTE POS are fully developed and approved, for the purposes of this document, the
terminology is CTE POS.
CTE POS receiving funding must be declared and implemented in the fall of 2011-2012.
Contact Ron Dodge, ron.dodge@state.or.us (503) 947-5653, in the office of Education
Improvement & Innovation (EII) for an implementation schedule.
‘‘(1) Strengthen the academic and career and technical skills of students participating in
career and technical education programs, by strengthening the academic and career and
technical education components of such programs through the integration of academics with
career and technical education programs through a coherent sequence of courses, such as
career and technical programs of study described in section 122(c)(1)(A), to ensure learning
in—
‘‘(A) the core academic subjects (as defined in section 9101 of the Elementary and
Secondary Education Act of 1965); and
‘‘(B) career and technical education subjects;
Approved CTE programs and CTE POS shall reflect a coherent and focused sequence of
courses based on industry standards, (e.g., local advisory committee endorsement,
adoption of career cluster program of study plan).
CTE courses shall include technical knowledge and skill content from the Oregon Skill Sets
and include content that addresses additional industry standards as appropriate.
Local Improvement Plans
Should an eligible recipient fail to meet 90% of one of the Perkins performance measures,
the recipient shall—
o In the first year of failing to meet one of the performance measures, implement an
improvement plan to specifically address the performance deficiency;
o If the same performance deficiency continues for a second year, update and
continue the improvement plan and direct Perkins funds toward addressing the
performance deficiency; and
o If the same performance deficiency continues for the third year, update and
continue the improvement plan and the Oregon Department of Education will
direct activities and local Perkins funding until the performance deficiency is
corrected.
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‘‘(2) link career and technical education at the secondary level and career and technical
education at the postsecondary level, including by offering the relevant elements of not less
than 1 career and technical program of study described in section 122(c)(1)(A);
Oregon high school and community college applying for funding shall implement and offer
one CTE POS by September 2008 and follow the 25% a year implementation schedule
established in January 2009. All CTE POS must be implemented by fall of 2011.
Aligned or articulated secondary-postsecondary CTE POS shall operate under the authority
of an institutional articulation agreement.
Each approved CTE POS shall explicitly identify (1) how the secondary CTE program aligns
or articulates to a postsecondary CTE program in the same program of study in a
nonduplicative way; and 2) what opportunities are provided a student to earn or transcript
dual or concurrent credit.
All Aspects of Industry
‘(3) provide students with strong experience in and understanding of all aspects of an
industry, which may include work based learning experiences;
Approved CTE POS shall provide the student with instruction beyond occupationally
specific skill attainment to include how a specific career fits into the larger system of an
industry.
Approved CTE POS with a work-based learning component should contribute to a student
satisfying the diploma requirement of career-related learning experiences.
Technology
‘‘(4) develop, improve, or expand the use of technology in career and technical education,
which may include—
‘‘(A)training of career and technical education teachers, faculty, and administrators to
use technology, which may include distance learning;
‘‘(B) providing career and technical education students with the academic and career
and technical skills (including the mathematics and science knowledge that provides
a strong basis for such skills) that lead to entry into the technology fields; or
‘‘(C)encouraging schools to collaborate with technology industries to offer voluntary
internships and mentoring programs, including programs that improve the
Mathematics and science knowledge of students;
Program instructional practice shall, to the extent practicable, use and model programrelated technology for the application of skills appropriate to the CTE POS (e.g.
instruction of skills practical to the level of skill attainment that is possible for the local
CTE program).
Technology-based equipment, software, and instructional material shall explicitly
contribute to student academic attainment, with specific attention to mathematics and
science, and technical skill attainment.
Technology-based equipment, software, and instructional material purchases shall be
limited to approved CTE POS that lead to high skill, high wage, or high demand
occupations in current or emerging careers.
Funds may be used to train teachers to implement technology however, costs for
distance education shall be limited to program or connectivity costs; not
student-related enrollment costs or fees.
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Legal Requirements for Use of Perkins IV Funds 2007-2013
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Evaluations
‘‘(6) develop and implement evaluations of the career and technical education programs
carried out with funds under this title
The secondary CTE program renewal process can be used as a tool for CTE program
evaluation.
Secondary CTE program evaluations shall be part of the ODE Continuous Improvement
Process (CIP).
Postsecondary CTE program evaluations shall be part of the college’s internal evaluation
and accreditation processes, except as it may relate to Local Improvement Plans
associated with failure to meet performance, in which case, a Perkins Improvement Plan
is required.
Improving and Expanding CTE
‘‘(7) initiate, improve, expand, and modernize quality career and technical education
programs, including relevant technology;
Relevant technology, equipment and related instructional material and supply purchases
are eligible expenditures as long as there is a direct and explicit connection between the
purchase of such items and increasing student academic knowledge and technical skill
attainment in the CTE POS. However, these should not be supplies that a school generally
provides.
The secondary program will use the CTE program renewal process to identify areas for CTE
POS improvement.
Sufficient Size, Scope & Quality
‘‘(8) provide services and activities that are of sufficient size, scope, and quality to be
effective; and
CTE POS that are designated as approved meet the criteria of “sufficient size, scope, and
quality to be effective” by having completed the secondary or postsecondary quality
assurance process.
Special Populations
‘‘(9) provide activities to prepare special populations, including single parents and displaced
homemakers who are enrolled in career and technical education programs, for high skill, high
wage, or high demand occupations that will lead to self-sufficiency
Analyze disaggregated CTE student performance to identify and design activities that
support special populations in meeting Perkins performance measures.
Review special population student pre-requisite—not remedial—requirements that equip
students with the readiness skills to be successful.
Remedial or developmental education activities are not eligible activities for the use of
Perkins funds. Funding support of pre-requisite courses for entry into a CTE POS may be
an eligible activity.
Special population student support for individuals already enrolled in a CTE POS as
described above is a required activity for the use of Perkins funds.
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PERMISSIVE USE OF PERKINS IV FUNDS
SECTION 135
Funds made available to an eligible recipient may be used for improving, enhancing, and
expanding CTE Programs of Study (CTE POS). All aspects of the use of Perkins funds must be
supported by data, rationale, a plan, and the school/institution must have the capacity to
measure student/program improvement resulting from the use of these funds.
Funding for new CTE POS must have prior state approval as Oregon is making its primary
investment in improving existing programs.
PERMISSIVE USE OF PERKINS IV FUNDS - SECTION 135
FUNDS TO A CONSORTIUM.
Funds allocated to a consortium formed to meet Perkins
requirements shall be used only for the purposes and programs that
are mutually beneficial to all members of the consortium and can be
used only for programs authorized. Such funds may not be
relocated to individual members of the consortium for purposes or
programs benefiting only one member of the consortium. [PL 109270.Sec131 (f)(2)]
SUPPLANTING:
”Sec. 311. Fiscal Requirements.
“(a) SUPPLEMENT NOT
SUPPLANT.- Funds made
available under this Act for
career and technical education
activities shall supplement, and
shall not supplant, non-Federal
funds expended to carry out
career and technical education
activates and tech prep program
activities.
Use of Perkins Funds to pay for any expense that was previously
paid by the local school district or college is considered
supplanting. This may include: salaries, textbooks stipends,
equipment, etc.
Perkins grant funds may not result in a reduction in state or local
funding that would have been available to conduct the activity had
federal funds not been received. Federal funds may not free up
state or local dollars for other purposes, should create or augment
the program to an extent not possible without federal dollars.
Your must be able to demonstrate that federal funds are added to
the amount of state and local funds that would, in the absence of
federal funds, be made available for uses specified in your plan.
Developing, implementing and
improving CTE POS
Activities that support the development of the 4 Core Elements of
Oregon’s CTE POS and the required student performance:
9 Standards and Content
9 Alignment and Articulation
9 Technical Skill Assessments
9 Student Support Services
Local Performance
Improvement Plan
A local improvement plan is required.
Schools, colleges and consortia not meeting state performance
targets must ensure that funds are expended to increase
performance first and foremost.
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Legal Requirements for Use of Perkins IV Funds 2007-2013
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PERMISSIVE USE OF PERKINS IV FUNDS - SECTION 135
Education and Business
To involve parents, businesses, and labor organizations as
appropriate. All grantees are required to have an active advisory
Partnerships and
committee; these committees may be shared between programs.
Collaboration
For local education and business partnerships;
9 To provide work-related experience, such as internships,
cooperative education, school-based enterprises,
entrepreneurship, and job shadowing (for students or
teachers)
9 Adjunct faculty arrangements for qualified industry
professionals
9 Internship for teachers
School to Career Activities
There is a prohibition clause within the Perkins legislation for use
of funds for School to Career activities. However, funds used for
CTE student career development is an allowable expense as a part
of a CTE POS.
Career and Technical Student
Organizations
Each program is expected to have student leadership identified. In
cases where schools cannot afford several student leadership
organizations (FFA, HOSA, etc.) the leadership component must be
identified within the CTE POS application.
To assist career and technical student organizations;
9 Leadership activities
9 Curriculum development
9 advisors
9 Conferences in which the primary purpose
is to disseminate technical information
9 Support of student CTE organization instruction that
is an integral part of the CTE POS
9 Instructional supplies, materials, and equipment needed to
support a student organization as an integral part of the
industry CTE POS.
9 Qualified CTE educators must supervise instruction that
relates to the student organization.
Restrictions apply;
9 Social assemblage and social conventions
9 Lodging, food, conveying or furnishing transportation to
conventions and other gatherings of CTSO students
9 Purchase of supplies, jackets and other effects for personal
ownership or usage
9 Cost of non-instructional activities such as athletic, social
or recreational events
9 Printing and disseminating of non-instructional materials
9 Purchase of awards for recognition of students, advisors or
other individuals; or payment of membership dues.
9 See non-allowable examples
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Legal Requirements for Use of Perkins IV Funds 2007-2013
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PERMISSIVE USE OF PERKINS IV FUNDS - SECTION 135
Regional Coordinators, Dual
5% Administrative cap is allowed.
Credit Coordinators and
Additional services must be directed to the 4 Core Elements of a
Pathway Coordinators
CTE POS according to the grant intent. The Reserve Grant focus
may change from year to year.
Services are for students of CTE POS.
Time records are required.
Consideration should be given to the Supplanting limitations. Is this
a service that has been or should be provided by the LEA?
All equipment purchased with Perkins funds must be for student
use or utilized in instructing students in the CTE POS>
Equipment:
“an article of nonexpendable,
tangible personal property
having a useful life of more
Equipment purchased solely for administrative/teacher use is not
than one year”.
allowed.
Supplanting rules apply
Equipment must be
“allowable” and improve
student performance.
Purchased early enough to enable an increase in student
performance during the fiscal year purchased. Beginning July 1,
2009 all equipment purchases must be made by December 1 of the
fiscal year.
Equipment Maintenance
Maintenance or equipment purchased with Perkins funds is
allowable as long as the expenditures adhere to the guidance in A87m Attachment B, item 25.
Equipment Labeling and
Inventory
The local school district must inventory any equipment purchased
with Perkins funds. All equipment must be marked with a
permanent marker or permanent label indicating grant source,
year of purchase, school name and program area. Inventory charts
are required; equipment must be removed it the program is no
longer an active POS.
Equipment Shared with
Disciplines other than CTE
The primary use of equipment purchased with Perkins funds should
be used by students who are enrolled in CTE POS. After the needs
of the CTE students are fully met, non-CTE students can use the
equipment.
Supplies
Costs incurred for materials, supplies and fabricated parts
necessary to carry out a CTE POS are allowable. However,
supplanting requirements must be addressed.
Leasing, purchasing, upgrading or adapting equipment, including
instructional aides;
9 Equipment over $5,000 must be pre-approved.
Not allowed: consumable supplies to be made into products to be
sold or to be used personally by students, teachers, or other person
(paper ink, CO2 cartridges, replacement batteries, toner,
replacement printer cartridges.
Oregon Department of Education 2009
Legal Requirements for Use of Perkins IV Funds 2007-2013
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Facility Construction
PERMISSIVE USE OF PERKINS IV FUNDS - SECTION 135
Renovation of the school facility cannot be funded by the Perkins
grant. Equipment/construction to start up or upgrade a CTE POS is
not allowable; i.e., greenhouses, storage buildings, equine stables,
barns.
Professional Development
Professional Development activities:
9 Are high quality, sustained, intensive and classroom focused
and a part of a professional development plan
9 Will help teachers and personnel improve student
achievement
9 Will help teachers and personnel: stay current with all
aspect of an industry; effectively develop rigorous and
challenging integrated curricula (jointly with academic
teachers, to the extent practicable, develop a higher level
of academic and industry knowledge and skills, and
effectively use applied learning.)
9 Promotes integration with profession
9 Dedicated 10% of each grant
Teacher Education Costs
A teacher’s educational costs (which are directly related to their
CTE POS, (tuition excepted), are an allowable expense. Course
work necessary to enhance teacher knowledge directly related to
CTE curriculum improvements or student instruction is permissible,
(i.e. CAD, Microsoft Office Suite.)
CTE Teacher Training
For teacher preparation programs that assist individuals who are
interested in becoming career and technical education instructors;
Industry experience for teachers and faculty
Teacher Travel to
National/State Conferences
Teacher travel to national and state professional development
conferences such as the National Business Educator’s Association is
an allowable expense if the documentation denotes that it meets
the Perkins requirements for Professional Development.
Conference attendees are responsible to share information with
other staff to make improvements to curriculum and in an effort to
improve overall program quality.
CTE Professional Organization
Memberships
Interdisciplinary /Integrated Curriculum Program Expense:
9 Expenses directly related to interdisciplinary
activities/courses tied to technical skill attainment (i.e.,
Math in CTE)
Effective July 1, 2009, travel to student leadership state and a
national conference is not allowable as teachers are primarily
responsible for student supervision and this cost is a responsibility
of the school district. (supplanting)
Not Allowed
Costs of membership in organization
Funds are not awarded to organizations engaged in lobbying
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Legal Requirements for Use of Perkins IV Funds 2007-2013
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PERMISSIVE USE OF PERKINS IV FUNDS - SECTION 135
CTE Teacher and Staff
Teacher and salary staff must be tied directly to CTE POS
implementation and to CTE POS students; time records are
Salaries
required documentation
Transitions to Postsecondary
School and district staff that is maintained beyond the three-year
period will be held accountable for supplanting, as ongoing staffing
is a responsibility of the local education agency
Activities specifically related to Perkins implementation
Costs for administration are limited to 5% of the grant
To develop and expand postsecondary program offerings at times
and formats that are accessible for students
New CTE Courses
To develop initiatives that facilitate the transition of sub
baccalaureate CTE students into baccalaureate degree programs
For improving or developing new CTE (within a POS) courses that
meet industry standards
Pre-requisite courses allowed; no remediation courses
Learning Communities
To develop and support small, personalized career themed learning
communities;
Distance learning connectivity fees (only)
Middle School Students
Oregon does not provide Perkins funding specifically for CTE in
middle schools.
Career Guidance
Mentoring and Student
Support
SEC. 315
“No funds under this Act may be used to provide career and technical
education programs to students prior to the seventh grade, except that
equipment and facilities purchased with funds under this Act may be used
by such students”
To provide assistance to individuals who have participated in
services and activities under this ACT in continuing their education
or training or finding an appropriate job
To provide career guidance and academic counseling for students
participating in CTE POS
For mentoring and outreach in non-traditional fields
Perkins funds may support a teacher and staff salaries to start up a
program and with maximum of three years of Perkins funds support
Supplemental staff including instructors, technicians, aides,
tutors, signer, note takers and interpreters for special population
students to support the attainment of skills in the classroom; but
not remedial courses
Leasing, purchasing, upgrading or adapting equipment, including
instructional aides or devices
Testing materials
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Adults and drop-outs
PERMISSIVE USE OF PERKINS IV FUNDS - SECTION 135
To provide CTE POS instructional programs for adults and school
dropouts.
Training in non-trad fields
To support training and activities in non-traditional fields.
Entrepreneurship
To provide activities to support entrepreneurship education and
training; cannot run businesses that undercut local businesses.
Automotive technologies
To provide support for training programs in automotive
technologies.
Family and Consumer Science
To provide support for family and consumer sciences programs;
Capital Expense
NO
To pool a portion of such funds for innovative initiatives with at
least one other eligible recipient, (e.g., improving the initial
preparation and professional development of CTE teachers,
faculty, administrators and counselors; establishing, enhancing or
supporting systems for Perkins accountability data collection or
reporting; implementing CTE POS; implementing technical
assessments and supporting other CTE activities that are consistent
with the purpose of the Perkins IV Act.)
(1) Capital Expenditures” means expenditures for the acquisition costs of
capital assets (equipment, building, land), or expenditures to make
improvements to capital assets that materially increase their value of
useful life. Acquisition cost means the cost of the asset including the cost
of modifications, attachments, accessories, or auxiliary apparatus
necessary to make it usable for the purpose for which it was acquired.
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NON-ALLOWABLE USE OF FUNDS
Funding activities that would supplant (replace) requirements of LEA
Remedial courses
Acquisition of equipment for administrative or personal use (NY State)
Expenditures for students not enrolled in CTE POS including career exploration, career fair, etc.
Requiring any secondary student to choose or pursue a specific career path, and or CTE delivery
model, and mandating student participation in a CTE program including a CTE program that
requires the attainment of a federally funded skill level, standards, or certificate of mastery
Capital Expenditures
Consumable supplies to be made into products to be sold or to be used personally by students,
teachers, or other person (paper ink, CO2 cartridges, replacement batteries, toner, replacement
printer cartridges)
Subscriptions to magazines or journals
Contingency or “petty cash” funds
Contributions and donations
Dues, memberships to professional organizations or societies
Equipment and supplies for building maintenance
Fines and penalties
Standard classroom furniture not unique to instruction program (except for new programs)
Furniture, files and equipment used by the teacher unless it is an integral part of an equipment
workstation or to provide reasonable accommodations to CTE POS students with disabilities
General storage files or cabinets not designed to store specific tools or equipment
Gifts, door prizes, etc.
Instructional aids, uniforms, tools or other items to be retained by students
Interest and other financial costs
Leasing vehicles, car rentals, etc.
Maintenance contracts or agreements, equipment repair and excessive installation costs
Meals, banquets entertainment
Promotional materials such as T-shirts, pens, cups, key chains
Tuition costs, university fees, distance learning fees
Videos, DVD, CD except for module based programs
Vehicles such as automobiles, trucks buses, airplanes, boats, golf carts, now mobiles,
motorcycles
Multiple copies of textbooks, except for new programs not previously provided by the school,
that support the increase of student performance and the curriculum is tied to current industry
standards
Effective Sept. O9, no computer labs (except as part of a new program).
Travel outside of the US
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